SecProbe.io

July 26, 2010
 Santana Martinez International Surf Resorts, Inc. 107 Country Coach Dr., Suite 705 Henderson, Nevada 89002
Re: International Surf Resorts, Inc.
 Post-Effective Amendment No.1 to Form SB-2 on Form S-1
Filed July 14, 2010 File No. 333-146182

Dear Mr. Martinez:
 We
have reviewed your registration statement and have the following comments. In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information. Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your response.
  After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

General
1. We note that your original registration stat ement was declared effective on October 4,
2007 and included your audited fi nancial statements for the year ended December 31,
2006.  In that registration statement, you undert ook to file post effective amendments in
order to update your prospectus pursuant to  Section 10(a)(3) of the Securities Act of
1933.  It appears that your fi rst Section 10(a)(3) update was required by July 4, 2008.
Please provide us with a lega l analysis of your compliance with Sections 5 and 10(a)(3)
of the Securities Act of 1933.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the filing to be certain that the filing includes the information the Securities Act of 1933 and all
applicable Securities Act rules require. Since the company and its management are in possession of
all facts relating to a company’s disclosure, they ar e responsible for the accuracy and adequacy of the
disclosures they have made.

Santana Martinez
International Surf Resorts, Inc. July 26, 2010 Page 2

Notwithstanding our comments, before we can declare the amended registration statement
effective, the company should provide us with a letter, acknowledging that :

• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please contact William Lewis at (202) 551-3722 or me at (202) 551-3655 with any
questions regarding this letter or related matters.
Sincerely,

Sonia G. Barros Special Counsel
  cc: Lan Ngyuyen  Esquire Consulting, Inc.   600 S. Spring Street #1312  Los Angeles, California 90014  ( via facsimile) (440) 848-6345